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Three years is the general rule — IRC § 6501(a), measured from the later of the due date or the date you filed. Six years if you omitted more than 25% of gross income. No limit at all for fraud — or for years where you never filed. And the audit clock is not the collection clock: collection runs ten years from assessment.
International tax compliance, offshore account disclosure, FBAR defense, asset protection, and proactive tax strategy for individuals with complex financial profiles.
Payroll tax problems, IRS audits, trust fund recovery penalties, and entity structuring issues. We defend businesses and their owners from the IRS and California tax agencies.
A 15-minute call done right gives you a clear assessment of your situation, a realistic outcome range, and a fee estimate — before you commit to anything.
Brotman Law represents U.S. persons with foreign accounts, foreign assets, and unreported foreign income who are facing IRS scrutiny or need to come into compliance. We also handle international tax defense for non-U.S. persons with U.S. tax obligations. Here is what that work looks like in practice.
Structuring your exit for the after-tax outcome — not the headline number.
The IRS Fresh Start program is real — but it’s not a single program, and it doesn’t work the way the TV ads describe. Here’s what it actually covers and how each component works in practice.
When the IRS denies your ERC claim or refuses to process it, litigation is the path that forces them to act. We file ERC lawsuits in federal court and Tax Court to recover the refunds our clients are owed.
EDD payroll tax penalties stack in layers. The base assessment includes unpaid UI, SDI, ETT, and PIT withholding across up to 12 quarters , then CUIC §1126 adds 15% for late filing, §1127 adds another 15% for negligence, and §1128 can add 50% for fraud — before Labor Code §226.8’s per-worker civil penalties even apply.
The U.S. Tax Court is the one forum where you can dispute the IRS before paying. We petition, litigate, and settle Tax Court cases for San Diego taxpayers — and prepare every case as if it will be tried.
An Offer in Compromise settles tax debt for less than you owe — when the numbers support it. We run the analysis honestly, file offers that can actually be accepted, and defend them through appeal.
Tax avoidance is legal. Tax evasion is a federal felony. The distinction turns on one word — willfulness — and what that word means in a criminal tax case is more specific than most people realize.
IRS Criminal Investigation is the only IRS division with law enforcement authority. Special agents are armed federal officers. If CI has contacted you or you suspect an investigation is open, here is how this works.
If the EDD sent you a Pre-Audit Questionnaire, a payroll tax audit has started — the questionnaire is the auditor’s first fact-gathering move, not paperwork. How you answer it shapes the entire worker-classification examination that follows. Here is what it asks, why each question matters, and how to respond without boxing yourself in.
Deferring capital gains on California investment property — and handling the mechanics, the QI, and the FTB clawback trap the right way.
An IRS audit is a legal dispute, not an accounting review. The type you’re dealing with tells you a lot about what the IRS thinks it found — and what your response should look like.
I represent individuals and businesses at every stage of IRS collections — from the first notice through CDP hearings, Offers in Compromise, and Tax Court litigation.
An IRS information document request — issued on Form 4564 — is one of the primary tools agents use during an examination. You are not required to produce every document requested. But ignoring an IDR has real consequences. Here’s how to respond strategically.
A continuous levy takes a portion of your paycheck every pay period until resolved. Unlike a bank levy, it doesn’t stop on its own.
An IRS payment plan allows you to pay off your tax debt in monthly installments instead of one lump sum. We help you choose the right plan type, negotiate affordable terms, and stay protected from IRS collection actions while you pay.
21-day hold, then funds transferred. If your account is frozen, you have a narrow window.
We file your Appeals protest, prepare the legal arguments, attend the conference on your behalf, and negotiate a settlement that avoids Tax Court litigation.
The IRS is offering a limited window to correct improper ERC claims with reduced penalties. We help you evaluate your exposure and choose the right correction path.
Letter 6612 gives you 30 days to respond with documentation proving your ERC eligibility under CARES Act Section 2301 — and every word in that response shapes whether the IRS disallows your credit, assesses penalties, or refers your case for criminal investigation. Brotman Law files Form 2848 the day you retain us so the IRS communicates with our team, not with you, from that point forward.
When an IRS civil exam carries criminal exposure — and what to do before the exam becomes a referral.
The False Claims Act carries treble damages and civil penalties up to $27,894 per false claim. We defend businesses facing FCA investigations and civil suits — including ERC fraud referrals, PPP loan allegations, and government contractor matters.
Brotman Law represents businesses and individuals named as defendants in qui tam lawsuits — not relators. If a whistleblower has filed a False Claims Act complaint against you, or you believe one has been filed, this is where to start.
A notice of deficiency is the IRS’s formal determination that you owe additional tax. From the date on the notice, you have 90 days to file a petition in U.S. Tax Court. That deadline is absolute.
A lien is a legal claim against your assets. A levy takes them. Here’s how to tell the difference and what you can do about a lien.
From IRS audits to tax debt resolution to proactive planning, Brotman Law provides comprehensive tax relief services for individuals and businesses throughout California. One firm, every tax solution.
Tax disputes happen in every state, not just California. We represent businesses and individuals in state tax controversies across the country — from New York to Texas to everywhere in between.
What to say, what not to say, and the procedure that follows. Revenue Officers do field collections work — not criminal investigations.
What founders need to understand before selling to a private equity buyer — rollover equity, management incentive units, deal structure, and the tax architecture that determines net proceeds.
Using a Charitable Remainder Trust to convert appreciated business stock into a tax-deferred lifetime income stream — when the math works, when it doesn’t, and how to structure it.
A strategic overview of how Brotman Law approaches complex tax issues cases.
Tax law services to help you protect you and your business from California and the IRS and regain your peace of mind.
Part of our comprehensive guide: The Complete Guide to California CDTFA Collections